DCT

2:25-cv-18851

Guangdong Aoyun Technology Co Ltd v. Shenzhenshi Lianheng Electronics Technology Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-18851, D.N.J., 12/22/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district by operating interactive e-commerce storefronts, purposefully directing sales to New Jersey consumers, and previously appearing in the District in a related action involving the same patent and products.
  • Core Dispute: Plaintiff alleges that Defendant’s wearable fan products infringe a patent related to a multi-stage fan module designed to increase airflow speed and reduce noise.
  • Technical Context: The technology concerns aerodynamic improvements in compact, portable electronic fans, a significant segment of the consumer electronics market.
  • Key Procedural History: The complaint alleges that Defendant previously appeared in the District of New Jersey in a related case (Doe v. The Partnerships, 2:25-cv-14859) concerning the same patent and accused products, where it opposed injunctive relief. Plaintiff asserts this prior action placed Defendant on actual notice of the alleged infringement.

Case Timeline

Date Event
2024-04-22 ’977 Patent Priority Date
2024-12-31 ’977 Patent Issue Date
2025-07-09 Plaintiff acquires ’977 Patent by assignment
2025-12-19 Date Plaintiff references for status of accused product listings
2025-12-22 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,180,977 - "High Speed Booster Fan Module", issued December 31, 2024 (’977 Patent)

The Invention Explained

  • Problem Addressed: The patent addresses the challenge that conventional small, portable fans are often low-powered, resulting in "poor air blowing and cooling effects," and can be noisy due to "turbulent air flow" (’977 Patent, col. 1:15-28).
  • The Patented Solution: The invention is a multi-component fan module that processes air in sequential stages to maximize output and minimize noise. An "air-driving fan blade group" first moves air into the module. This airflow is then accelerated by a "booster fan." Next, an "airflow direction guiding member" directs the flow into a uniform axial direction. Finally, a "rectifying and boosting hood" performs a secondary boost and removes turbulence before the air is expelled (’977 Patent, col. 1:33-62; Fig. 1). This four-part system is designed to increase wind speed and air supply distance while achieving "an effect of silence and noise reduction" (’977 Patent, col. 1:40-42).
  • Technical Importance: The claimed solution provides a specific aerodynamic architecture intended to overcome the inherent performance limitations of compact, battery-powered fans by improving airflow efficiency rather than simply increasing motor power. (Compl. ¶25).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" of the ’977 Patent without specifying which claims are asserted (Compl. ¶2). Independent claim 1 is representative and includes the following essential elements:
    • An air duct with an air inlet and an air outlet.
    • An "air-driving fan blade group" arranged in the air duct to blow air towards the outlet.
    • A "booster fan" arranged at the air outlet.
    • An "airflow direction guiding member" arranged after the booster fan.
    • A "rectifying and boosting hood" arranged after the guiding member.
    • A sequence of functions performed by these components: the booster fan boosts the initial airflow, the guiding member directs the boosted flow parallel to an axial direction, and the hood performs a final boost while removing turbulence.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "wearable fan products" sold by Defendant under the brand name "Astaowl" (Compl. ¶¶ 2, 19). The complaint identifies two primary product types—"single-duct" and "dual-duct" wearable fans—sold under at least fourteen different Amazon Standard Identification Numbers (ASINs), including representative models B0DZFQCXRY, B0D7BWWKVK, and B0DCB6B6S8 (Compl. ¶¶ 27-28, 30).

Functionality and Market Context

The products are described as sharing the "same underlying fan structure and operating principles" (Compl. ¶28). The complaint alleges that Plaintiff conducted a "physical inspection and analysis" of purchased representative products to determine that they practice the claimed invention (Compl. ¶¶ 36-37). The products are sold to U.S. consumers through e-commerce platforms, including Amazon.com (Compl. ¶3). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that detailed infringement claim charts are attached as Exhibits 3-A, 3-B, and 3-C, which map "representative claims of the Asserted Patent to each of those three purchased products" (Compl. ¶¶ 37, 41). These exhibits were not available for this analysis. The complaint’s narrative theory of infringement asserts that a physical inspection of the accused Astaowl fans demonstrates that they "practice each limitation of at least one asserted claim of the Asserted Patent, either literally or under the doctrine of equivalents" (Compl. ¶38). The complaint further states that the claim charts contain "annotated photographs of the purchased products" as evidence of infringement (Compl. ¶39).

Identified Points of Contention

  • Scope Questions: The infringement analysis may focus on whether the accused consumer-grade wearable fans contain the distinct, four-part structural sequence required by claim 1 (air-driving fan, booster fan, guiding member, rectifying hood). A central question may be whether a single physical component in the accused products is alleged to perform the functions of multiple claimed elements, and if such a configuration meets the claim limitations.
  • Technical Questions: A key factual dispute may arise over whether the structures within the accused fans perform the specific functions recited in the claims. For example, what evidence demonstrates that a particular component "boosts" the airflow as a "booster fan," that another structure "guides the air flow...in a direction parallel to an axial direction," and that the outlet nozzle performs the dual function of "boosting and turbulence removal" as a "rectifying and boosting hood"? (’977 Patent, col. 5:46-64).

V. Key Claim Terms for Construction

The Term: "booster fan"

  • Context and Importance: This term is critical as it defines the first stage of airflow acceleration after the main fan blades. The presence and specific structure of this element in the accused products will be a central point of the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 describes the "booster fan" functionally as boosting "the air flow output by the air-driving fan blade group" and structurally as being "arranged at the air outlet" (’977 Patent, col. 5:51-52, 56-58). This could support an argument that any structure at the outlet that increases airflow speed meets the limitation.
    • Evidence for a Narrower Interpretation: Dependent claim 2 and the specification describe the booster fan more specifically as comprising a "plurality of tangential wind boosting blades" that form a "ring-like boosting air duct" (’977 Patent, col. 2:62-65; col. 6:1-3). This language may be used to argue that the term requires a distinct set of angled, stationary blades, not merely a shaped duct.

The Term: "rectifying and boosting hood"

  • Context and Importance: This is the final claimed element and is recited as performing a dual function. Whether the simple outlet nozzle of the accused fan meets this two-part functional requirement will be a likely point of contention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests a functional definition, stating the hood "outwards blows the air flow...after performing boosting and turbulence removal" (’977 Patent, col. 2:57-62). An argument could be made that any nozzle shape that smooths and accelerates airflow meets this functional description.
    • Evidence for a Narrower Interpretation: The specification describes this component as having an "inner diameter...[that] radially decreases," which "can further compress the air flow...not only increase the speed, but also eliminate a portion of the turbulence phenomenon" (’977 Patent, col. 4:55-61). This suggests a specific converging nozzle geometry is required to perform the claimed function.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendant’s infringement has been and continues to be willful (Compl. ¶44). The basis for this allegation is Defendant’s purported "actual notice of the Asserted Patent and Plaintiff’s allegations of infringement since at least service of Plaintiff’s prior complaint asserting the same patent against Defendant's accused products" (Compl. ¶31). It is alleged that Defendant continued to sell the accused products despite this notice (Compl. ¶32).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of structural correspondence: Do the accused Astaowl wearable fans, likely designed for cost-effective manufacturing, incorporate the specific four-stage air-handling architecture recited in the ’977 Patent (air-driving fan, booster fan, guiding member, and rectifying hood), or does their construction use a more integrated design that may not map onto each distinct claimed element?
  • A key evidentiary question will be one of functional performance: Does the physical structure of the accused fans actually perform the sequence of distinct aerodynamic functions required by the asserted claims—including boosting airflow at two separate stages and actively guiding it—or is there a fundamental mismatch between the claimed technical operation and that of the accused products?
  • The allegation of willfulness will depend on the factual record of the prior litigation mentioned in the complaint, specifically when and how Defendant was put on notice of its alleged infringement of the ’977 Patent.